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1401
McKinney, Suite 2400, · Houston, Texas 77010
Phone
713.759.2600
Margaret
E. Carriere
Senior
Vice President and Corporate Secretary
February
8, 2006
VIA
EDGAR, FACSIMILE (202) 942-9579 and U.S. Mail
Cecilia
D. Blye, Chief
Office
of
Global Security Risk
United
States
Securities
and Exchange Commission
100
F.
St. N.E.
Washington,
D.C. 20549-5546
Reference: Halliburton
Company
Form
10-K for the Fiscal Year Ended December 31, 2004
Filed
March 1, 2005
File
No. 001-03492
Dear
Ms.
Blye:
This
is
in response to your letter addressed to our President and CEO, David J. Lesar,
dated December 30, 2005.
Response
to Comments 1, 2 and 3
Libya
Activities
in Libya occur through the Libyan Branch of Halliburton G.m.b.H., a German
corporation headquartered in Celle, Germany. The Libyan Branch of Halliburton
G.m.b.H. had revenue of approximately $31 million in 2004 for conventional
oil
field services work in Libya. Approximately 185 employees work in Libya for
this
German corporation. With the lifting of Libyan sanctions in 2004, this German
corporation is attempting to increase its activities to include more specialized
drilling services. We estimate revenues for 2005 to be about $40 million.
Oilfield software supplied by our Landmark Graphics unit is being provided
to
worldwide customers, some of whom use it for operations in Libya.
Brown
and
Root (NA) Limited, a British Virgin Islands ( BVI) corporation, is a 50 - 50
joint venture with another BVI entity ultimately owned by the Libyan government.
The company operates mostly in Libya. It is in the final stages of providing
engineering assistance on the Great Man Made River Project, a project to provide
irrigation to desert areas in Libya. Nothing is exported from the United States
to support this project. Historical KBR share of operational revenue has ranged
as high as $10 - $20 million annually, but was only $4 to $5 million for 2004
and 2005. KBR, the Halliburton subsidiary which manages this investment, intends
to divest itself of its 50% shareholding in Brown & Root (NA) Ltd in the
first half of 2006.
All
Libyan revenues combined were less than $40 million for 2004, or less than
one
quarter of 1% of the company’s revenue. Particularly in light of the small scale
of activities, we see no negative impact on shareholders or investors. We do
not
believe our contracts with Libya constitute a material investment risk to our
shareholders. We are not aware that any person or entity has made the decision
to invest or not to invest in Halliburton based on activity in Libya, nor do
we
think it likely that they would do so.
Syria
The
company has no active operations in Syria. Effective January 31, 2005, the
company announced that it would cease to undertake new work in Syria, subject
to
completing existing contractual commitments. Sales to Syria for 2004 were only
$453 thousand, all consisting of Landmark Graphics oilfield software. Sales
for
2005 declined to $21 thousand, again consisting of Landmark Graphics oilfield
software. These Syrian sales represent less than one one-hundredth of 1% of
the
company’s revenue for the periods discussed. No sales are anticipated for 2006.
We believe that there is no impact on investors or investor sentiment relating
to activities in Syria.
If
you
have questions, please call me at 713-759-2617.
Sincerely
yours,
/s/
Margaret Carriere
Margaret
Carriere